State v. Moyer, 2019 Ohio 1187

Shawn Moyer pleaded guilty in 2017 to amended aggravated trafficking (third-degree felony) and was sentenced to four years of community control with a reserved 36-month prison term.
While on community control, Moyer faced a separate indictment (18-CR-00141) for aggravated burglary and felonious assault; he later pled guilty to felonious assault and received a four-year prison term.
A motion to revoke community control in the trafficking case alleged the new charges and alcohol use; Moyer admitted consuming alcohol while on supervision.
The trial court revoked community control and imposed the reserved 36-month prison sentence on August 2, 2018, finding imprisonment consistent with R.C. 2929.11 and 2929.12 and noting the offense was committed while on supervision.
Moyer appealed, arguing the trial court erred by imposing prison without making the specific findings required by R.C. 2929.13(E)(2)(a) or (b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by imposing prison after revoking community control without making R.C. 2929.13(E)(2) findings	State: Court properly revoked; substantial proof of violation and sentence lawful	Moyer: Court failed to make the requisite statutory findings before imposing prison	Court: No error — record shows consideration of R.C. 2929.11/2929.12; sentence within statutory range and supported by record

State v. Marcum, 146 Ohio St.3d 516 (establishes R.C. 2953.08 standard for appellate review of felony sentences)
State v. Bonnell, 140 Ohio St.3d 209 (appellate review of sentences and when findings are required)
State v. Foster, 109 Ohio St.3d 1 (severed mandatory judicial findings under R.C. 2929.14; discretionary sentencing within statutory range)
State v. Kalish, 120 Ohio St.3d 23 (discusses post-Foster appellate review framework)
Cross v. Ledford, 161 Ohio St. 469 (defines clear-and-convincing evidence standard)